Evidence has been introduced that
the complaining witness,1
<insert name of complainant>, may be culpable in the alleged offense. You must consider the credibility of <insert name of complainant> in
light of any motive (he/she) might have for testifying falsely and incriminating
the accused, <insert name of defendant>.

In evaluating the testimony of this
witness, you should consider (his/her) appearance and demeanor as a witness, the
reasons given for (his/her) coming forward and telling (his/her) story to the
authorities, and whether any motive has appeared or any reason is apparent why
(he/she) would accuse the defendant.

You must consider and compare
(his/her) testimony with all the other testimony and evidence in the case. It
is up to you to determine whether to believe this witness. Like all other
questions of credibility, this is a question you must decide based on all the
evidence presented to you.
_______________________________________________________

Generally, the court should not instruct the jury on the credibility of a
particular witness, but the Supreme Court has recognized three exceptions: the
complaining witness, an accomplice, and an informant. See State v. Patterson,
276 Conn. 452, 470 (2005); State v. Ortiz, 252 Conn. 533, 561-62 (2000).

The complaining witness exception
was first discussed in State v. Cooper, 182 Conn. 207 (1980), in which
the Court said "[s]ince the complaining witness could himself have been subject
to prosecution depending only upon the veracity of his account of this
particular criminal transaction, the court should have instructed the jury in
substantial compliance with the defendant's request to charge to determine the
credibility of that witness in the light of any motive for testifying falsely
and inculpating the accused. We emphasize, however, that in order for the
request to be applicable to the issues in the case, there must be evidence, as
there was here, to support the defendant's assertion that the complaining
witness was the culpable party." Id., 212. See also State v. Baltas,
311 Conn. 786, 818-22 (2014) (evidence of witness's possible participation in
the crime was sufficient to justify an instruction on her motive to testify
falsely); State v. Keiser,
196 Conn. 122, 133 (1985) (insufficient evidence that witness was a culpable
party).

"To be sufficient to implicate
culpability, the evidence must directly connect a complaining witness to the
crime with which the defendant is charged. . . . It is not sufficient to raise a
mere suspicion that the witness may have committed the crime." State v.
Sinchak, 47 Conn. App. 134, 144 (1997). "It is not enough to show that the
party had a motive to commit the crime . . . nor is it enough to raise a mere
suspicion that he may have committed the crime" (Citations omitted.) State
v. Byrd, 34 Conn. App. 368, 373 (1994).